Beyond the Scope: Why RTI Cannot Be Your Personal Grievance Redressal Forum

In a definitive ruling that reinforces the constitutional boundaries of the Right to Information (RTI) Act, the Central Information Commission (CIC) has dismissed an appeal filed by an employee of the Airports Authority of India (AAI) against his employer. The judgment, delivered by Information Commissioner Anandi Ramalingam, serves as a stark reminder that the RTI Act is a mechanism for transparency, not an instrument for litigating personal workplace disputes.

A Quest for Clarity or a Path to Litigation?

The dispute involved Arun R. A., an employee at the Vijayawada Airport, who filed two successive RTI applications in April 2024. His queries were deeply personal and legalistic, focusing on internal HR decisions, the alleged non-compliance of AAI with Kerala High Court orders regarding rank list revisions, and requests for internal authorizations explaining why certain documents were withheld from him.

The AAI, acting through its Central Public Information Officer (CPIO), maintained that the requested information had been provided where available, or that the queries sought hypothetical justifications rather than actual records. Dissatisfied with the responses, the appellant elevated his case to the Commission, arguing that the AAI's responses were evasive and suppression of facts.

Arguments from the Trenches

The Appellant contended that the AAI’s failure to provide specific internal communications amounted to a "constructive refusal" to disclose information vital to his service career. He argued that the CPIO’s reliance on the argument that the rank list had been updated was misleading and that the authority was guilty of contempt regarding court mandates.

Conversely, the Respondent (AAI) argued that the RTI applications were used to mask a service grievance. They emphasized that the queries were "repetitive," that the applicant sought justifications/deductions rather than facts, and that the requested information had already been communicated via official channels. The respondent maintained that any further grievances regarding seniority or service conditions fell outside the purview of the RTI regime.

The Legal Analysis: RTI vs. Adjudication

The Commission leaned heavily on established Supreme Court precedents to draw a line in the sand. At the heart of the matter is Section 2(f) of the RTI Act, which defines 'information' as material already held by the public authority.

Commissioner Ramalingam reiterated that the RTI Act does not require a public authority to provide advice, opinions, or to construct justifications for their actions. Specifically, the Commission noted that:

* The Act is restricted to records existing in the public authority's possession.

* Citizens cannot force an authority to provide an explanation for "why" a decision was taken.

* RTI proceedings cannot be converted into a forum to adjudicate the correctness of administrative actions.

Key Observations

The judgment draws upon pivotal apex court rulings that define the scope of information access:

> "A public authority is also not required to furnish information which require drawing of inferences and/or making of assumptions. It is also not required to provide 'advice' or 'opinion' to an applicant." — CBSE vs. Aditya Bandopadhyay & Ors.

> "The definition [of information] cannot include within its fold answers to the question why which would be the same thing as asking the reason for a justification for a particular thing." — Dr. Celsa Pinto vs. The Goa State Information Commission

> "...proceedings under the RTI Act cannot be converted into proceedings for adjudication of disputes as to the correctness of the information furnished." — Hansi Rawat and Anr. v. Punjab National Bank and Ors.

The Decision: A Lesson in Boundaries

Ultimately, the Commission dismissed the appeal, noting that the Appellant was attempting to "channelize a grievance" through the RTI route. The decision underscores a crucial takeaway for public officials and citizens alike: the RTI Act is a tool for systemic accountability, not for micro-managing individual HR grievances or forcing public authorities to act as legal advisors to employees.

For future applicants, this judgment acts as a warning: if you are using RTI as a substitute for a court of law or an internal grievance cell, you are likely to face dismissal. The Commission remains firm that it lacks the mandate to adjudicate "other controversies or disputes" beyond the scope of providing access to existing information.